What CDM 2015 says about welfare facilities
Schedule 2 of CDM 2015 sets out minimum welfare requirements — sanitary facilities, washing, rest, changing, and drinking water — that must be provided and maintained from the start of the construction phase.
The Construction (Design and Management) Regulations 2015 place legal duties on clients, principal designers, principal contractors, contractors, and designers across all notifiable construction projects. For principal contractors, the welfare duties are set out primarily in Schedule 2 of the Regulations, and supported by the HSE's welfare guidance for construction sites.
Schedule 2 requires principal contractors to provide and maintain:
- Sanitary conveniences (toilets) — adequate number for the workforce, separated by sex or individually lockable, ventilated, lit, and kept clean
- Washing facilities — including showers where work is particularly dirty or involves exposure to hazardous substances; hot and cold (or warm) water; soap and towels (or dryers)
- Drinking water — readily accessible, clearly marked as drinking water
- Changing rooms and lockers — where workers have to wear special clothing and cannot reasonably be expected to change elsewhere
- Rest facilities — with means to warm food and boil water, seating with tables, and protection from bad weather
The word “maintained” in Schedule 2 is significant. Facilities must not simply be provided — they must be kept in working order, adequately stocked (soap, paper, hot water), and in a clean and orderly condition throughout the construction phase. This is an ongoing obligation, not a one-time installation requirement.
How many welfare facilities does a construction site need?
The HSE uses a ratio-based approach: one toilet and one washbasin per 25 workers as a minimum — with additional provision required for larger workforces.
CDM 2015 does not specify exact ratios, but the HSE's welfare guidance provides practical numbers based on the maximum number of people on site at any one time. These are minimum requirements — the principal contractor should always provide more where the nature of the work (for example, muddy groundworks requiring showers) demands it.
| Number of workers on site | Minimum toilets | Minimum washbasins |
|---|---|---|
| 1–5 | 1 | 1 |
| 6–25 | 2 | 2 |
| 26–50 | 3 | 3 |
| 51–75 | 4 | 4 |
| 76–100 | 5 | 5 |
On projects with a mixed workforce of men and women, the above figures apply to each sex separately — unless the site uses individual lockable cubicles (combined toilet and washbasin), in which case the ratios can be applied to the total workforce. On sites where the workforce is predominantly male, the ratios can be adjusted if urinals are provided in addition to sit-down WCs.
The key point: welfare provision is calculated on peak occupancy, not average daily attendance. If a site regularly peaks at 60 workers during key construction phases, it needs 4 toilets and 4 washbasins available during those phases — even if the average daily attendance is lower.
Construction dust and COSHH — why HEPA vacuums matter
Fine construction dust — including respirable crystalline silica — is a controlled substance under COSHH. Standard vacuums re-circulate it; HEPA vacuums capture it.
One of the most commonly misunderstood aspects of construction site cleaning is dust control. The HSE's guidance on construction dust identifies three main types of hazardous dust on construction sites: silica dust (from cutting, grinding, or drilling stone, concrete, and masonry), wood dust (from machining or sanding wood), and lower toxicity dusts (general construction dust from other materials).
Silica dust is classified as a Group 1 carcinogen by the International Agency for Research on Cancer. Prolonged exposure causes silicosis — an incurable and progressive lung disease — and increases the risk of lung cancer. The COSHH Regulations 2002 require employers to prevent or adequately control workers' exposure to silica dust, including controlling dust at the point of generation and using effective dust extraction equipment.
For post-construction cleaning — whether of welfare facilities during the build, or the final sparkle clean before handover — standard vacuum cleaners and dry brushing re-circulate fine dust particles into the air rather than capturing them. This creates a dust exposure risk for the cleaning operatives and contaminates areas that have just been cleaned. Only HEPA (High Efficiency Particulate Air) filtered vacuum equipment can capture particles small enough to include respirable silica — rated H class (EN 60335-2-69) for the finest particles.
This is why specifying “HEPA vacuum equipment” in a construction cleaning specification is not an optional enhancement — it is a COSHH compliance requirement when post-construction cleaning involves disturbing settled construction dust.
What to include in your Construction Phase Plan for welfare cleaning
CDM 2015 requires the Construction Phase Plan to address welfare arrangements — including how facilities will be maintained. A welfare cleaning schedule should be a named deliverable.
On notifiable projects, the principal contractor must prepare and maintain a Construction Phase Plan (CPP) before construction begins. The CPP must include arrangements for managing the project, including welfare arrangements. In practice, the welfare section of many CPPs is generic and vague — which creates problems when HSE inspects and asks to see the plan.
A robust CPP welfare section for a project that will last more than a few weeks should include:
- The number and type of welfare facilities to be provided, and where they will be located on the site
- The welfare cleaning contractor's name, and their cleaning schedule (frequency per week, which facilities covered)
- How welfare consumables (soap, paper, hot water) will be restocked and who is responsible
- How welfare facility condition will be monitored and recorded (daily inspection by site manager, or by the cleaning contractor)
- The arrangements for the post-construction sparkle clean before handover
Naming the welfare cleaning contractor and their schedule in the CPP transforms welfare cleaning from an informal arrangement into a documented programme — which is exactly what HSE expects to see when they inspect. If an improvement notice is issued for inadequate welfare, the principal contractor can demonstrate that a cleaning programme was in place and show the inspection records. Without documentation, there is no defence.
How Vigil structures welfare cleaning contracts for London construction sites
Vigil contracts align to the build programme — welfare cleaning frequency is set at site assessment, adjusted as headcount changes, and documented with digital visit records throughout.
Vigil provides construction site welfare cleaning across all 32 Greater London boroughs on programmes typically running from 12 to 24 months, aligned to the build timeline. Our approach:
- Site assessment first: We visit the site before agreeing any programme. We review the CDM welfare plan, assess current and peak worker headcount, and inspect the welfare facilities to determine appropriate cleaning frequency by area and occupancy level.
- Programme-aligned contract: Your welfare cleaning contract is structured against your build programme — not against a calendar. We flex frequency and scope as the programme progresses (for example, increasing during groundworks when welfare usage peaks).
- CDM documentation support: We provide a written welfare cleaning specification that can be incorporated into your Construction Phase Plan, and digital visit records after every clean that are formatted for site diaries, HSE inspections, and handover packs.
- HEPA sparkle cleans: The sparkle clean before practical completion is included in your programme contract, timed against your handover date. We use HEPA H-class equipment as standard, with a written sign-off report for your handover documentation.
Because all Vigil operatives are directly employed, DBS checked, and COSHH-trained before deployment to any site, you have a documented supply chain for your welfare cleaning that can withstand HSE scrutiny and client audit. Agency-sourced or subcontracted cleaning creates documentation gaps that are difficult to close when a regulator asks to see training records.
External references
Common questions
CDM 2015 welfare cleaning — frequently asked questions
CDM 2015 Schedule 2, paragraph 7 requires that suitable and sufficient sanitary conveniences are provided at readily accessible places. They must be adequately ventilated and lit, kept in a clean and orderly condition, and, where reasonably practicable, include separate rooms for men and women — or lockable individual facilities. The HSE guidance on welfare facilities specifies that the number of toilets required increases with the number of workers on site: at least one toilet and one washbasin for every 25 workers, or at least two toilets for 26–50 workers, with additional provision for larger sites. Cleaning frequency is not specified in the Regulations in terms of a fixed number of visits, but the requirement to maintain facilities in a "clean and orderly condition" implies regular cleaning — in practice, daily or twice-weekly minimum depending on site size.
Under CDM 2015, the principal contractor is responsible for the welfare facilities on a construction site. The client has a duty to ensure that suitable construction work-related welfare facilities are available before and during the build, but the day-to-day management and maintenance of those facilities — including arranging their cleaning — falls to the principal contractor. Clients can discharge their duty by confirming with the principal contractor at tender stage that adequate welfare facilities will be provided and maintained, and by checking compliance periodically during the build. On notifiable projects (where the project will last more than 30 working days with more than 20 workers simultaneously, or exceed 500 person-days), the principal contractor must also include welfare arrangements in the Construction Phase Plan.
CDM 2015 does not prescribe a specific cleaning frequency — it requires facilities to be "in a clean and orderly condition." The HSE guidance on construction site welfare interprets this as regular cleaning appropriate to the level of use. For a small site with 5–10 workers, twice-weekly cleaning may be adequate. For a larger site with 30+ workers, daily cleaning — and in some cases two cleans per day for heavily-used toilet blocks — is typically required to maintain the required standard. HSE inspectors assess welfare facilities in a practical way: if a toilet block on a 50-person site is visibly unclean, inadequately stocked, or unpleasant to use, they will issue an improvement notice regardless of how frequently the cleaning roster says it has been cleaned. The test is the condition of the facility, not the cleaning schedule.
A post-construction sparkle clean (often called a "sparkle" or "builders clean") is a detailed deep clean of a building carried out after construction and fit-out works are complete, and before practical completion or handover to the client or incoming occupier. It removes construction dust, cement splatter, paint spots, adhesive residue, label stickers, and other construction debris from all surfaces, including: all floor finishes (hard and soft), all joinery and window frames, all sanitary ware, all fixed furniture, glazing, ironmongery, and light fittings. A HEPA-filtered vacuum is required for the dust extraction phase — standard vacuums re-circulate fine construction dust particles (including potentially silica dust) rather than capturing them, which is both a health risk and a quality failure. A Vigil sparkle clean includes HEPA equipment as standard, with a written completion report and photographic sign-off suitable for inclusion in handover documentation.
If an HSE inspector visits a construction site and finds that welfare facilities are inadequate — insufficient toilets, facilities not cleaned, no hot water or soap, no rest facilities — they can take several types of enforcement action. An Improvement Notice requires the principal contractor to rectify the specific issue within a defined timescale (minimum 21 days). A Prohibition Notice prohibits the activity causing the risk immediately and can effectively stop work on part or all of the site. In serious cases — particularly where there is evidence of persistent non-compliance or where the inadequacy is affecting multiple workers — the HSE can pursue a prosecution. Prosecution under the Health and Safety at Work Act 1974 can result in unlimited fines for organisations and potential imprisonment for individuals. CDM welfare breaches are taken seriously — the HSE publishes its enforcement actions and they appear in company and director searches.